Righthaven LLC v. Newman

Filing 13

MOTION to Withdraw as Attorney with Certificate of Service by Anne Pieroni. by Plaintiff Righthaven LLC. Motion ripe 4/6/2011. (Attachments: # 1 Proposed Order Granting Motion to Withdraw)(Pieroni, Anne)

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ANNE E. PIERONI, ESQ.
Nevada Bar No. 9650
[e-mail]
9960 West Cheyenne Avenue, Suite 210
Las Vegas, Nevada 89129-7701
Tel.: [phone]
Fax: [phone]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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RIGHTHAVEN LLC, a Nevada limitedliability company,

Case No.: 2:10-cv-01762-JCM-PAL

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MOTION AND PROPOSED ORDER TO
WITHDRAW AS COUNSEL OF RECORD
WITH CERTIFICATE OF SERVICE

Plaintiff,
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v.
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GARRY NEWMAN, an individual,
Defendant.

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ANNE E. PIERONI, ESQ. respectfully moves this court for an order permitting

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Anne Pieroni, Esq. ("Ms. Pieroni"), who has appeared in these proceedings, to withdraw as

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counsel for Righthaven LLC ("Righthaven"), in the above captioned matter, pursuant to Local

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Rule IA 10-6, S.C.R 46, and N.R.P.C 1.16 (b)(1) and (7). This Motion is made and based upon

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the Memorandum of Points and Authorities submitted herein, as well as the pleadings and papers
on file herein.
MEMORANDUM OF POINTS AND AUTHORITIES

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Ms. Pieroni is no longer employed as counsel at Righthaven. Furthermore, Ms. Pieroni
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was not retained to represent Righthaven as outside counsel, in the above captioned matter, or
any other pending case or matter before this Court on behalf of Righthaven. The Local Rule IA

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10-6 (a) provides that "No attorney may withdraw after appearing in a case except by leave of

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court after notice served on the affected client and opposing counsel." Righthaven received

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notice of Ms. Pieroni’s intent to withdraw from this case, and all other Righthaven cases, upon

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Ms. Pieroni’s final week of employment with Righthaven.

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Additionally, all parties in this case will receive notice of this Motion to Withdraw via the
CM/ECF system, pursuant to the certificate of service attached herein. Additionally, Local Rule
IA 10-6 (e) provides that "no withdrawal... shall be approved if delay of discovery, the trial or

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any hearing in the case would result." Here, no delay of any kind will result from Ms. Pieroni's
withdrawal because Righthaven is represented in this matter by outside counsel, Shawn A.

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Mangano, Esq., who is filing a Notice of Appearance in this matter concurrently herewith, as

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well as represented by various in-house counsel employed by Righthaven. Ms. Pieroni's

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withdrawal will not prejudice either party or delay any proceeding in this matter.
CONCLUSION

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For the reasons set forth above, Ms. Pieroni respectfully moves this Court to enter an
Order approving the withdrawal of Ms. Pieroni as a counsel of record for Righthaven in the
above captioned matter.
Dated this 6th day of April, 2011.
By: /s/ Anne E. Pieroni, Esq.
ANNE E. PIERONI, ESQ.
Nevada Bar No. 9650
[e-mail]
9960 West Cheyenne Avenue, Suite 210
Las Vegas, Nevada 89129-7701
Tel.: [phone]

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IT IS SO ORDERED:
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_______________________________
UNITED STATES DISTRICT JUDGE

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DATED: ______________________

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CERTIFICATE OF SERVICE

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Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that on this 6th day of
April, 2011, I caused a copy of the MOTION AND PROPOSED ORDER TO WITHDRAW

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AS COUNSEL OF RECORD WITH CERTIFICATE OF SERVICE to be served by the
Court’s CM/ECF system.

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By: /s/ Anne Pieroni

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